OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

December 11, 2001

Mr. Magnus Thuresson
855 Hazel Trail
Crownsville, MD 21032-1822

Re: Vertical Hand Tool Grinder

Dear Mr. Thuresson:

This is in response to your letter of May 24, 2001 to Keith Goddard of the Maryland Occupational Safety and Health Administration, requesting an interpretation on hand tool shielding requirements. We understand that you would like us to address your question with respect to federal Occupational Safety and Health requirements.

A state that administers its own OSHA program is required to have a program that is at least as protective as the federal OSHA requirements. However, it may enact more stringent requirements. For this reason, it is important to keep abreast of current changes in the State's plan for Maryland employers. Feel free to contact:

Use of pneumatic hand tool with a small circular diamond cutting blade

From your original submission and subsequent correspondence with OSHA's Regional staff, we understand the operation involved and tool use to be as follows:

The tool configuration at issue consists of a 4- or 6-inch circular, electroplated diamond metal cutting blade mounted on a rotary pneumatic angle-drive hand-held tool. The pictures supplied show that the tool was designed for and equipped with a blade guard.

You state that you use this combination of tool and cutting blade to cut access holes in PVC piping. Then, from the inside, you cut off excess piping, which extends beyond the interior face of a manhole wall. This use requires cutting the pipe from its interior and leaves the cut edge flush with the manhole wall.

The operator first cuts a hole in the pipe that is large enough so that the cutting tool may be maneuvered inside the pipe. The operator then cuts the pipe section protruding into the manhole by cutting the PVC pipe around the inside circumference, rather than the outside. The operation is performed in this manner because space and process limitations do not permit the pipe to be removed for more traditional cutting. The PVC piping is an insert to repair or alter existing piping running between manholes.1

Applicability of OSHA's construction standards

Both OSHA's General Industry and Construction Standards identify construction work as follows: 29 CFR 1926.32(g) and 29 CFR 1910.12(b) define construction work as: "work for construction, alteration, and/or repair, including painting and decorating." Your operation, which involves the installation of new PVC piping in a manhole, is usually construction work.

Answer:
Hand and power tools used in construction are covered under 29 CFR Part 1926 Subpart I §§1926.300-1926.307, "Tools -- Hand and Power." General requirements for use are in §1926.300. In particular, §1926.300(b)(1) "Guarding" requires that, "when power operated tools are designed to accommodate guards, they shall be equipped with such guards when in use."

The photograph you supplied with your request indicated that your pneumatic angle drive hand-held tool was designed for and supplied with a guard. Therefore, the standard requires that you use that guard during your hole cutting and cut-off operations.

We understand that use of the tool with the guard in place makes it difficult to do this operation. There are other types of tool and blade combinations that may be better suited for your pipe cutting operations. Cutting-off tools rather than angle drives might be better suited to cutting from the inside of the pipe and provide more protection for the operator. Some of these are powerful battery operated tools. Alternatively, a lighter weight air-hose (whip) would make your tool more maneuverable and easier to get inside the pipe, which could significantly reduce the hazards associated with using a pneumatic tool in the close-quarters you describe. Please call us for more technical information.

Additionally, §1926.302 Power-operated hand tools require positive connections between the air supply hose or whip and the tool to prevent accidental disconnections. Section 1926.302(b)(1) requires that "Pneumatic power tools shall be secured to the hose or whip by some positive means to prevent the tool from becoming accidentally disconnected."

If you need additional information, please call us at 202-693-2345 or send us a fax addressed to the Occupational Safety and Health Standard Administration (OSHA), [Directorate of Construction, Standards and Guidance] at (202) 693-1689.

Sincerely,

Russell B. Swanson, Director
Directorate of Construction

1We note that the operator faces significant hazards during this process. For instance, the operator is exposed to the rotating cut-off blade during both the hole cutting and cut-off procedures; the tool has no trigger guard to protect the operator against accidental activation/deactivation during positioning or use of the tool; also there is no indication of positive means to prevent accidental airline disconnection and employee exposure to airline whipping. The risk of serious injury is increased by the confined or enclosed nature of the space in which the employee is performing the pipe cutting operation. This letter will not address the hazards of confined or enclosed spaces.[ back to text ]

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